Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Depreciation - only the lessee can be treated as owner of the asset in case of a finance lease - No depreciation can be allowed to the lessor in such a case of a genuine finance lease - AT
Depreciation - only the lessee can be treated as owner of the asset in case of a finance lease - No depreciation can be allowed to the lessor in such a case of a genuine finance lease - AT
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